Sands, R. v [2026] EWCA Crim 15 (20 January 2026)

Sands, R. v [2026] EWCA Crim 15 (20 January 2026)

The trial judge's directions on the use of evidence relating to the appellant's past behaviour were adequate and tailored to the issues of consent; the s.41 rulings were correct and within the judge's discretion; and the sentence, though severe, was not manifestly excessive given the aggravating features and harm caused.

Citation
[2026] EWCA Crim 15
Parties
Respondent: Rex; Appellant: Lloyd Sands
Jurisdiction
England and Wales
Judgment Date
20 January 2026
Procedural Posture
Criminal Appeal / Appeal From Crown Court Conviction and Sentence
Outcome
Appeal against conviction and sentence dismissed; renewed application for leave to appeal refused.
Legal Topics
Rape, Attempted Rape, Voyeurism, Consent, Bad Character Evidence, Section 41 Applications, Sentencing
Criminal Law Rape Attempted Rape Voyeurism Consent Bad Character Evidence Section 41 Applications Sentencing

Case Brief

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Parties

Rex

Respondent

Lloyd Sands

Appellant

Procedural Posture

Criminal Appeal / Appeal From Crown Court Conviction and Sentence

Legal Issues

  1. 1 Whether the trial judge failed to give adequate directions on the use of evidence about the appellant's past behaviour under s.98 Criminal Justice Act 2003
  2. 2 Whether the judge erred in her rulings under s.41 Youth Justice and Criminal Evidence Act 1999 regarding cross-examination on the complainant's sexual behaviour
  3. 3 Whether the sentence imposed was manifestly excessive

Ratio Decidendi

The trial judge's directions on the use of evidence relating to the appellant's past behaviour were adequate and tailored to the issues of consent; the s.41 rulings were correct and within the judge's discretion; and the sentence, though severe, was not manifestly excessive given the aggravating features and harm caused.

Court Disposition

Appeal against conviction and sentence dismissed; renewed application for leave to appeal refused.